SBK-L-12266, Supplement to License Amendment Request 10-02, Application for Change to the Technical Specifications for the Containment Enclosure Emergency Air Cleanup System

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Supplement to License Amendment Request 10-02, Application for Change to the Technical Specifications for the Containment Enclosure Emergency Air Cleanup System
ML13037A089
Person / Time
Site: Seabrook NextEra Energy icon.png
Issue date: 01/31/2013
From: Walsh K
NextEra Energy Seabrook
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
SBK-L-12266, TAC ME3988
Download: ML13037A089 (14)
v • d • e


Text

NEXTera ENERG-YV, January 31, 2013 10 CFR 50.90 SBK-L-1 2266 Docket No. 50-443 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Seabrook Station Supplement to License Amendment Request 10-02, "Application for Change to the Technical Specifications for the Containment Enclosure Emergency Air Cleanup System"

References:

1. NextEra Energy Seabrook, LLC letter SBK-L-1 0074, "Application for Change to the Technical Specifications for the Containment Enclosure Emergency Air Cleanup System," May 14, 2010
2. NextEra Energy Seabrook, LLC letter SBK-L-10143, Response to Request for Additional Information Regarding License Amendment Request (LAR) 10-02, "Application for Change to the Technical Specifications for the Containment Enclosure Emergency Air Cleanup System," August 24, 2010
3. NextEra Energy Seabrook, LLC letter SBK-L-1 1184, Response to Request for Additional Information Regarding License Amendment Request 10-02, Regarding the Containment Enclosure Emergency Air Cleanup System, September 16, 2011
4. NextEra Energy Seabrook, LLC letter SBK-L-12054, Response to Request for Additional Information Regarding License Amendment Request 10-02, "Application for Change to the Technical Specifications for the Containment Enclosure Emergency Air Cleanup System," March 15, 2012
5. NRC letter "Seabrook Station, Unit 1 - Request for Additional Information Regarding the Addition of Action Statement to Limiting Condition for Operation 3.6.5.1, "Containment Enclosure Emergency Air Cleanup System" (TAC No. ME3988)," June 11, 2012
6. NextEra Energy Seabrook, LLC letter SBK-L-1 2124, Response to Request for Additional Information Regarding License Amendment Request 10-02, Regarding the Containment Enclosure Emergency Air Cleanup System, July 2, 2012 NextEra Energy Seabrook, LLC, P.O. Box 300, Lafayette Road, Seabrook, NH 03874 A 00

United States Nuclear Regulatory Commission SBK-L-1 2266 / Page 2 In Reference 1 and supplemented by References 2, 3, 4, and 6, NextEra Energy Seabrook, LLC (NextEra) submitted a request for an amendment to the Technical Specifications (TS) for Seabrook Station. The proposed amendment would relocate TS Surveillance Requirement (SR) 4.6.5.1 .d.4, which verifies the ability to establish a negative pressure in the containment enclosure building, so that it will demonstrate integrity of the containment enclosure building rather than operability of the containment enclosure emergency air cleanup system. The amendment relocates SR 4.6.5.1.d.4 with modifications as new SR 4.6.5.2.b. Additionally, the amendment makes some minor wording changes, deletes a definition, and removes an expired footnote.

The proposed change would resolve a discrepancy in required actions between TS 3.6.5.1 for the Containment Enclosure Emergency Air Cleanup System (CEEACS), and TS 3.6.5.2, Containment Enclosure Building Integrity. Currently, TS 3.6.5.2 allows 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to restore containment enclosure building integrity. However, the same condition (lack of containment enclosure building integrity) would require entry into TS 3.0.3 for two inoperable trains of CEEACS due to an inoperable ventilation area boundary. The proposed change will resolve this discrepancy so that only the actions of TS 3.6.5.2 would apply to a failure to maintain containment enclosure building integrity.

The NRC issued a similar change in February 1996 for Millstone 3 in Amendment 126. The safety evaluation (SE) for the amendment discusses that a conflict was identified relative to Millstone TS 3.6.6.1, Supplementary Leak Collection and Release Systems (SLCRS), during planned breaches of the secondary containment. TS 3.6.6.2, Secondary Containment, provides 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to restore secondary containment boundary operability. However, a planned breach in the secondary containment would render both trains of SLCRS inoperable (due to the inability to satisfy the surveillance requirement that demonstrates the ability to establish a negative pressure in the secondary containment). This condition would require a plant shutdown in accordance with TS 3.0.3. The NRC staff's SE states that the proposed changes will resolve this problem by decoupling TS 3.6.6.1 and 3.6.6.2; the licensee will, when breaching the secondary containment, enter only the Action Statements for TS 3.6.6.2. In the event that secondary containment operability is not maintained, the Action Statement for LCO 3.6.6.2 requires that secondary containment operability must be restored within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Further, the SE states "The staff has determined that 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is a reasonablecompletion time considering the limited leakage design of containment and the low probabilityof a design basis accident occurringduring this period." Moreover, the SE states "This situation was recognized by the staff and has been addressedin the improved standardtechnicalspecification for Westinghouse plants (NUREG-1431)."

In NUREG-1431, the surveillance requirement that verifies the ability to maintain a negative pressure in the shield building is associated with TS 3.6.8, Shield Building, rather than TS 3.6.13, Shield Building Air Cleanup System (SBACS), as a demonstration of shield building integrity. Therefore, a failure to maintain shield building integrity does not render both trains of the SBACS inoperable. Furthermore, similar to the change approved for Millstone in Amendment 126, NUREG -1431 provides a 24-hour completion time to restore an inoperable shield building. The basis for this completion time included in NUREG-1431 is also the same as that approved for Millstone 3: Twenty-four hours is a reasonable Completion Time considering the limited leakage design of containment and the low probabilityof a Design Basis Accident occurringduring this time period.

United States Nuclear Regulatory Commission SBK-L-1 2266 / Page 3 NextEra is proposing a change to eliminate the TS discrepancy that would require a TS 3.0.3 plant shutdown for a failure to maintain containment enclosure building integrity. The current Seabrook TS provide a 24-hour completion time to restore containment enclosure building integrity; however, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is not an acceptable completion time for a loss of function for the Seabrook containment enclosure building because the building access openings contain a single door. Therefore, to avoid an unnecessary, immediate plant shutdown in the event that containment enclosure building integrity is not maintained, NextEra proposes to supplement the requested amendment. The supplement provides new required actions that are based on the cause of the loss of integrity and includes a new action with a completion time of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

NextEra discussed the revised proposed changes with the NRC staff in a conference call on January 17, 2013.

Proposed action a provides 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to restore containment enclosure building integrity when performing corrective or preventative maintenance on the containment enclosure boundary or following discovery of an inoperable containment enclosure boundary component (penetration seal, damper, or access door). Twelve hours is a reasonable completion time considering the limited leakage design of containment, the low probability of a design basis accident occurring during this time, and the time required to repair a containment enclosure building door. Further, without containment enclosure building integrity, the containment building spray (CBS) system provides additional defense-in-depth for accidents that credit the containment enclosure building. The CBS system functions to remove iodine and reduce containment pressure, which reduces containment leakage to the containment enclosure. As a result, the CBS system reduces dose consequences from a release from the primary containment. Without at least one CBS train operable, the TS require an immediate plant shutdown.

Proposed action b provides a 24-hour completion time for the condition in which an operable containment enclosure boundary door is held open to support movement of equipment through the access opening, or routing hoses, cables, etc., through the access opening. This action requires the availability of a dedicated individual with a preplanned method to rapidly close the containment enclosure boundary door in the event of actuation of the CEEACS. The dedicated individual must be stationed at the door and have continuous communications capability with the control room. Hoses and cables running through the access opening must employ a means that allows prompt removal of the obstruction to permit closure of the door without delay. Twenty-four hours is a reasonable completion time considering the limited leakage design of containment, the low probability of a DBA occurring during this time, and the availability of a dedicated individual to close the containment enclosure boundary door. provides a revised markup of the TS showing the proposed changes, which replaces and supersedes the markup of TS 3.6.5.2 provided in Reference 6, and Attachment 2 contains the retyped TS page. Attachment 3 provides revised TS Bases that replace and supersede the proposed Bases for TS 3.6.5.2 provided in Reference 6. The Bases are provided for information and will be implemented in accordance with TS 6.7.6.j, TS Bases Control Program, upon implementation of the license amendment.

The modification to the proposed change does not alter the conclusion in Reference 1 that the proposed change does not involve a significant hazard consideration pursuant to 10 CFR 50.92.

United States Nuclear Regulatory Commission SBK-L-1 2266 / Page 4 A copy of this letter has been forwarded to the New Hampshire State Liaison Officer pursuant to 10 CFR 50.91(b).

Should you have any questions regarding this letter, please contact Mr. Michael O'Keefe, Licensing Manager, at (603) 773-7745.

Sincerely, NextEra Energy Seabrook, LLC Kevin T. Walsh Site Vice President Enclosure cc: NRC Region I Administrator J. G. Lamb, NRC Project Manager, Project Directorate 1-2 NRC Senior Resident Inspector Perry E. Plummer, Acting Director, Homeland Security and Emergency Management New Hampshire Department of Safety Division of Homeland Security and Emergency Management Bureau of Emergency Management 33 Hazen Drive Concord, NH 03305 John Giarrusso, Jr., Nuclear Preparedness Manager The Commonwealth of Massachusetts Emergency Management Agency 400 Worcester Road Framingham, MA 01702-5399

NExTerao ENERGY d AFFIDAVIT SEABROOK STATION UNIT 1 Facility Operating License NPF-86 Docket No. 50-443 Supplement to License Amendment Request 10-02, "Application for Change to the Technical Specifications for the Containment Enclosure Emergency Air Cleanup System" I, Kevin T. Walsh, Site Vice President of NextEra Energy Seabrook, LLC hereby affirm that the information and statements contained within this supplement regarding License Amendment Request 10-02 are based on facts and circumstances which are true and accurate to the best of my knowledge and belief.

Sworn and Subscribed before me this

\ day of .*.x u &. ,2013 Kevin T. Walsh N~ayPublic) Site Vice President

Attachment 1 Markup of TS 3.6.5.2

CONTAINMENT SYSTEMS CONTAINMENT ENCLOSURE BUILDING CONTAINMENT ENCLOSURE BUILDING INTEGRITY LIMITING CONDITION FOR OPERATION 3,6.5.2 CO,'AINrvEN-rENCI*OSUR* BULLDNG I, TE-$RI shall be maintained.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTION: '- 'a",,

( itho ONTA LOS RE

~T ENCL S RE BQILDI~G DING VJ lFT{Ywith~iq hour or b r tore CO~ANM NT) least ~S DY within=thennt 6hou s and ih.COLD SH LfDOWN with the'follio-w 3 os SURVEILLANCE REQUIREMENTS 4.6.5.2 ri*AQ-KMZ ENT E WO,2'UR EeUI L Na G . shall be demonstratedo l-ieasn5 per "lay~sby veifying What the doortn each aclcefssop~eniing is c~losed e~xcept*

the accesenin cis beýing used for normal transit entry a~nd exi .I l,?

-/4 aye,?

1"71 SEABROOK - UNIT 1 3/4 6-24

INSERT NOTE

IL j I'--------------------------------------------------

Entry into ACTION is not required when the access opening is being used for normal transit entry or exit.

INSERT ACTIONS

a. Without containment enclosure building integrity for reasons other than Action b, restore containment enclosure building integrity within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Otherwise be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
b. Without containment enclosure building integrity when equipment ingress and egress requires the access door to be maintained open, verify a dedicated individual, who is in continuous communication with the control room, is available to rapidly close the door; and restore containment enclosure building integrity within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Otherwise be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

Attachment 2 Retyped Page for TS 3.6.5.2

CONTAINMENT SYSTEMS CONTAINMENT ENCLOSURE BUILDING CONTAINMENT ENCLOSURE BUILDING INTEGRITY LIMITING CONDITION FOR OPERATION 3.6.5.2 Containment enclosure building integrity shall be maintained.

APPLICABILITY: MODES 1, 2, 3, and 4.

NOTE ---------------------------

Entry into ACTION is not required when the access opening is being used for normal transit entry or exit.

ACTION:

a. Without containment enclosure building integrity for reasons other than Action b, restore containment enclosure building integrity within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Otherwise be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
b. Without containment enclosure building integrity when equipment ingress and egress requires the access door to be maintained open, verify a dedicated individual, who is in continuous communication with the control room, is available to rapidly close the door; and restore containment enclosure building integrity within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Otherwise be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> SURVEILLANCE REQUIREMENTS 4.6.5.2 Containment enclosure building integrity shall be demonstrated:
a. At least once per 31 days by verifying that the door in each access opening is closed except when the access opening is being used for normal transit entry and exit, and
b. At least once per 36 months on a STAGGERED TEST BASIS by verifying the containment enclosure building can be maintained at a negative pressure greater than or equal to 0.25 inch water gauge by one train of the containment enclosure emergency air cleanup system within 4 minutes after a start signal.

SEABROOK - UNIT 1 3/4 6-23 Amendment No.

Attachment 3 Bases for TS 3.6.5.2

3/4.6.5.2 CONTAINMENT ENCLOSURE BUILDING INTEGRITY BACKGROUND The containment enclosure building is a reinforced concrete right cylindrical structure with a hemispherical dome that is located outside and surrounds the containment building. This structure provides leak protection for the containment and protects it from certain loads (normal loads, loads due to severe and extreme environmental conditions, and abnormal loads). The space between the containment and the enclosure building is maintained at a slight negative pressure during accident conditions. All joints and penetrations are sealed to ensure air tightness.

Without containment enclosure building integrity, the containment building spray (CBS) system provides additional defense-in-depth for accidents that credit the containment enclosure building. The CBS system functions to remove iodine and reduce containment pressure, which reduces containment leakage to the containment enclosure. As a result, the CBS system reduces dose consequences from a release from the primary containment. When Action a or b is entered, the plant can continue to operate at power if at least one CBS train is operable in accordance with TS 3.6.2.1.

APPLICABLE SAFETY ANALYSES The function of the containment enclosure building is to collect any fission products which could leak from the primary containment structure into the containment enclosure and contiguous areas following a LOCA. The containment enclosure provides a barrier between the containment and the environment to control all leakage out from the containment boundary.

Containment enclosure building integrity ensures that the release of radioactive materials from the primary containment atmosphere will be restricted to those leakage paths and associated leak rates assumed in the safety analyses. This restriction, in conjunction with operation of the containment enclosure emergency air cleanup system (CEEACS), will limit radiation dose to within the dose guideline values of 10 CFR 50.67 during accident conditions.

The containment enclosure building satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO Containment enclosure building integrity must be maintained to limit the release of radioactive materials from the primary containment atmosphere to those leakage paths and associated leak rates assumed in the safety analyses. Containment enclosure building integrity exists when (1) each door in each access opening is closed except when the access opening is being used for normal transit entry and exit, (2) the sealing mechanism associated with each containment enclosure building penetration (e.g., welds, bellows, or 0-rings) is OPERABLE, and (3) the containment enclosure building functions as designed to maintain the required negative pressure.

APPLICABILITY Maintaining containment enclosure building integrity prevents leakage of radioactive material from the enclosure building. Radioactive material may enter the containment enclosure building from the containment following a DBA. Therefore, containment enclosure integrity is required in 1

MODES 1, 2, 3, and 4 when a DBA could release radioactive material to the containment atmosphere. In MODES 5 and 6, the probability and consequences of these events are low due to the Reactor Coolant System temperature and pressure limitations in these MODES.

Therefore, containment enclosure building integrity is not required in MODE 5 or 6.

ACTIONS A Note states that entry into the Actions is not required when an access opening (containment enclosure boundary door) is being used for normal transit entry and exit. This provision provides an exception to TS 3.0.1 when containment enclosure integrity is not maintained while an access door is open for normal transit. This note is consistent with SR 4.6.5.2.a, which requires each containment enclosure boundary door to be closed except during normal transit entry and exit.

Action a.

Action a addresses a loss of containment enclosure building integrity for reasons other than provided in Action b. For example, this action is applicable when performing preventative or corrective maintenance on the containment enclosure building boundary, including containment enclosure building penetration seals, dampers and access doors, that results in a failure to maintain containment enclosure building integrity. The containment enclosure building access openings contain a single door, so opening a door causes a loss of containment enclosure integrity.

Containment building enclosure integrity must be restored within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Twelve hours is a reasonable completion time considering the limited leakage design of containment, the low probability of a DBA occurring during this time, and the time required to repair a containment enclosure building door.

Action b.

Action b addresses the condition in which an OPERABLE containment enclosure boundary door is held open to support movement of equipment through the access opening, or routing hoses, cables, etc., through the access opening. Thus, this action applies when containment enclosure building integrity is not maintained due to an open access door for equipment ingress and egress because the doorway must be maintained open, i.e., obstructed, for equipment, cables, hoses, etc., such that it cannot be immediately closed. Additionally, pressure boundary seals must also be intact to maintain the integrity of the containment enclosure. Action b does not apply to normal transit entry and exit.

Action b requires the availability of a dedicated individual with a preplanned method to rapidly close the containment enclosure boundary door in the event of actuation of the CEEACS. The dedicated individual must be stationed at the door and have continuous communications capability with the control room. Hoses and cables running through the access opening must employ a means that allows prompt removal of the obstruction to permit closure of the door without delay.

Containment building enclosure integrity must be restored within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Twenty-four hours is a reasonable completion time considering the limited leakage design of containment, the low probability of a DBA occurring during this time, and the availability of a dedicated individual to close the containment enclosure boundary door.

2

SURVEILLANCE REQUIREMENTS SR 4.6.5.2.a The containment enclosure boundary doors are normally maintained closed except when the access opening is being used for entry and exit. Verifying containment enclosure building integrity involves confirming that the doors are closed except during normal transit entry and exit.

Normal transit includes opening doors as necessary to permit the movement of people and equipment through the doorway. This may also include opening doors to test actuation of door alarms. Propping open a door and obstructing the doorway with equipment, cables, hoses, etc.,

such that it cannot be immediately closed is not normal transit entry and exit. Additionally, pressure boundary seals must also be intact to maintain the integrity of the containment enclosure.

SR 4.6.5.2.b The CEEACS is used to establish a negative pressure in the containment enclosure building.

SR 4.6.5.2 verifies containment enclosure building integrity by drawing down the containment enclosure building to a negative pressure greater than or equal to 0.25 inch Water Gauge using one train of CEEACS within four minutes after a start signal to ensure that the building can meet its design negative pressure in less than eight minutes following the initiation of a LOCA.

Inoperability of the containment enclosure building does not by itself render the CEEACS inoperable. Therefore, the Action of TS 3.6.5.1 (CEEACS) is not required to be entered solely due to a failure to maintain containment enclosure building integrity.

Since this SR is a containment enclosure building boundary integrity test, it does not need to be performed at each surveillance interval with each CEEACS train. The CEEACS train used for this SR is scheduled on a STAGGERED test basis to ensure that either train will perform the test. The primary purpose of this SR is to ensure containment enclosure building integrity. The secondary purpose of this SR is to ensure that the CEEACS train used for the test functions as designed. Inoperability of the CEEACS train does not necessarily constitute a failure of this SR relative to containment enclosure building integrity.

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